F1RST Parking PCN – Bewl Water – Paid via Ringo but still charged £100

The land on which your car was observed via ANPR camera’s is private land. Only the water/reservoir is governed by Medway Water/Southern Water.

Send the following email to First Parking by first class post and get a free certificate of posting from any post office to First Parking LLP, 27 Old Gloucester Street, London, WC1N 3AX:

Quote

Subject: Formal complaint – Breach of PPSCoP 8.1.1(d) and KADOE (Keeper liability misrepresented at Bewl Water)

Dear First Parking LLP Complaints Team,

I write as the registered keeper in relation to Parking Charge Notice [PCN ref], issued at Bewl Water on 17/09/2025.

Your Notice to Keeper (NtK) states or implies that you are able to hold me (the Keeper) liable under Schedule 4 to the Protection of Freedoms Act 2012 (PoFA). That statement is incorrect for this location and places you in breach of the Private Parking Single Code of Practice (PPSCoP), section 8.1.1(d). As you know, a breach of the PPSCoP is also a breach of your DVLA KADOE contract.

Why PoFA keeper liability cannot apply at Bewl Water
PoFA Sch 4 excludes “relevant land” where parking is “subject to statutory control” (Sch 4, para 3(1)(c) and 3(3)).

Bewl Water is a statutory reservoir/undertaking created and governed by specific legislation, including:

• Medway Water (Bewl Bridge Reservoir) Act 1968 (local Act establishing the scheme; authorising works and land acquisition).
• Reservoirs Act 1975 (statutory safety regime imposing duties on the undertaker for inspection, maintenance and emergency planning).

The presence of this statutory framework means the land is under statutory control for PoFA purposes, irrespective of present operational or ownership arrangements.

References (official sources)

• PoFA 2012]Protection of Freedoms Act 2012, Sch 4, para 3(1)(c), 3(3):
• Medway Water (Bewl Bridge Reservoir) Act 1968 (1968 c. xxxiii) (official PDF available)
• Reservoirs Act 1975: legislation.gov.uk

Breach of PPSCoP and KADOE
PPSCoP 8.1.1(d) requires that operators must not state or imply that keeper liability applies where Schedule 4 does not. By asserting PoFA keeper liability at Bewl Water, your NtK misrepresents the legal position. This is a Code breach and, consequently, a breach of the DVLA’s KADOE terms, which require adherence to the applicable Code as a condition of data access.

Required remedies
As this is a formal complaint, please confirm within 14 days how you will rectify this compliance failure. At minimum, I expect you to:

1. Cancel PCN [PCN ref] and confirm in writing that no keeper liability is pursued at Bewl Water.
2. Cease and correct all NtK templates and website wording for sites under statutory control to remove any assertion (or implication) of PoFA keeper liability.
3. Conduct an immediate audit of outstanding NtKs issued for Bewl Water (and any other sites under statutory control) and notify affected keepers accordingly.
4. Provide details of staff guidance/training updates to prevent recurrence.

If you do not provide a satisfactory response, I will escalate this complaint to the British Parking Association and to the DVLA for investigation of a PPSCoP/KADOE breach.

Your published complaints policy states complaints must be submitted by post. For the avoidance of doubt, I will only accept your response by post or by email (your choice). Do not require telephone contact, web portals or third-party platforms for complaint handling or evidence review. Please treat this email as a formal complaint and provide your written response by [date – 14 days from today].

Yours faithfully,

[Full name]

[Postal address]
[Email]
Registered Keeper of vehicle [VRM]
PCN: [reference]